CONCORD – Working on Waste, a citizens’ initiative focused on safe alternatives to incinerators and landfills, has added its voice to groups who say the New Hampshire Department of Environmental Services’ draft solid waste management plan is not aggressive enough to embrace change.
“The 25% diversion target under Project DES is troublesome and reflects deference to a waste industry that favors the disposal and import of waste,” Katie Lajoie commented on behalf of Working on Waste. “We seek to have the zero-waste hierarchy replace the inefficient, disposal-focused hierarchy noted on page three of the draft.”
August 26 was the deadline for submitting public comments, and Michael Nork, who is drafting the new plan on behalf of the Solid Waste Division, said comments will be posted on the DES website soon.
State law requires a solid waste management plan that outlines goals, strategies, and actions to reduce the amount of solid waste sent to landfills through source reduction and waste diversion in order to ensure sufficient capacity to manage government solid waste. The plan has not been updated since 2003.
The Conservation Law Foundation, which had filed a lawsuit challenging DES’s years-long failure to update the plan, also criticized the project, saying “any progress is a step in the right direction”, but that the DES “blatantly ignored the law requiring an updated waste management plan. The draft plan, he said, “is inadequate and irrelevant. New Hampshire needs, DES only provided a long list of recommendations, with no real steps to achieve them.
CLF added, “Without the leadership of DES, New Hampshire will continue to be a dumping ground for garbage from Massachusetts and other states.”
The criticism echoes comments from the statutorily appointed Solid Waste Task Force, which is helping DES update its solid waste management plan. At its last meeting, members said the plan did not articulate strongly enough the need to reduce the amount of solid waste sent to landfills.
Marc Morgan, Solid Waste Manager in Lebanon and member of the task force, said: “I’m trying to do something here that makes a difference in our solid waste diversion, and all the things we’re talking about are just one bunch of words…[T]this is an emergency that we do not talk about enough, which is specific to climate change. … He has to move much more aggressively than kicking the road to 2030 or 2050.”
Working On Waste also criticized the department’s response to the cumulative effects of toxins. The ministry wrote: “With respect to the assessment of the cumulative toxic effects of emissions of multiple pollutants and the long-term accumulation of persistent toxic pollutants, the law does not provide [the] Department a regulatory basis on which to establish limits based on these parameters.
WOW commented: “Failure to address cumulative and synergistic impacts signals the need for new and aggressive action to protect the public from lead, mercury, cadmium, dioxin, PFAS and other chemicals for all time. New Hampshire’s current regulatory framework does not adequately address key characteristics of persistent toxic substances commonly released from disposal sites. Persistent toxic substances bioaccumulate and pose a public health risk over generations.
The group wants to see legislative and regulatory measures to solve the problems posed by solid waste.
Nork said in a phone conversation that DES is reviewing the approximately 80 comments it received during the public comment period.
“We want to work very diligently to make sure that we review and read everyone’s comments and consider them,” Nork said. “We will be working over the next two weeks to ensure that we finalize the plan in accordance with the October 1 deadline, and we will consider how we can incorporate feedback as appropriate.”
Calling the plan a “work in progress”, Nork said: “We are doing our best to work within the time frame we have. At this time, it is not appropriate for me to comment on what we think or the terms of the process. We really have to work internally to be able to get through this and work as efficiently as possible.
The solid waste task force canceled its August and September meetings to give the state time to complete the plan, so it won’t have time to comment before the final report is released.
State Sen. James Gray, R-Rochester, also sits on the task force, and he expressed disappointment that he didn’t have a chance to weigh in on the final version. He said it didn’t make sense to him, given that the group was tasked with helping prepare the plan.